EMERI©O Design 7 8285 SW NIMBUS AVE, SUITE 180. BEAVERTON, OREGON 97008 TEL : (503) 746-8812 FAX : (503) 639-9592 wwwemeriodesign.com Appendix I Impact Evaluation and Environmental Review Application dated January 2017 Mitigation and Monitoring Plan dated January 2017 Memo regarding BES Sewer Project Completeness Item dated January 17, 2017 Memo regarding Streams, wetlands and floodplains Completeness Item dated January 4, 2017 Memo regarding Wetland Delineation dated July 26, 2016 by Schott & Associates, Inc.SCHOTT & ASSOCIATES Ecologists & Wetlands Specialists 21018 NE Hwy 99E * PO. Box 589 + Aurora, OR 97002 * (503) 678-6007 * FAX: (503) 678-6011 Impact Evaluation and Environmental Review Application for Macadam Ridge Prepared for Stephen Griffith Riverview Abbey Prepared by Schott and Associates PO Box 589 Aurora, OR 97002 S&AH2321 January 2017Introduction The proposed project consists of 23 detached single-family houses north and west of Taylors Ferry Road and east of SW 1* Street in the City of Portland. Zoning for the property is R10c and R10p, The site is mapped within the Southwest Hills Resource Protection Plan within Sites 116 and 117. As identified on the City zoning map, the project is within the mapped Environmental Conservation overlay (“o”) zone with a drainage system mapped within the Environmental Protection overlay (“p”) zone. The applicant proposes development within the zone which does not meet all development standards and requires Environmental Review as per Section 33.430.220. The purpose of this application is to outline the proposed development plan and provide an impact evaluation, This report will provide the required additional information such as identification of onsite resources, functional values and alternatives analysis as well as a construction management plan and mitigation plan required by 33.430.240B. During the design and planning process for the proposed development the applicant has been conducting onsite investigational work. In the process two Zoning Violations have been incurred Violation 1 was for topping trees/shrubs within the environmental conservation and protection overlays planted as mitigation for LU 06-107286. Violation 2 was for ground disturbance with a track ‘machine within the resource area of the EC zone without required review. In order to resolve these violations the applicant is adding Environmental Violation Review to this application. Site Deserip ‘The subject property consists of four tax lots (T1$ RIE Sec.22CB TL#1300, 4200, 4300 and a portion of TIS RIE Sec.22CA TL#2600) located north and west of SW Taylors Ferry Road and east of SW 1* Avenue and Ruby Terrace. Nearly the entire property is located within mapped Environmental Conservation and Environmental Protection Overlay zones. The site is bounded to the east by the Riverview Mausoleum. The southern boundary is defined by SW Hume St and SW Taylors Ferry Road, To the north and west are residential homes. The residentially-zoned property consists of mostly forested vacant land, Steep north and south facing slopes converge with a northeast-flowing tributary (Ruby Creek) joining the main stem of Stephens Creek at the northeast comer of the project boundary. Stephens Creek flows east along the northern part of the property before flowing offsite and under SW Taylors Ferry Road At the time of the site visit, the site was heavily forested with a canopy of big leaf maple (Acer ‘macrophyllum) and a few Douglas fir trees (Pseudotsuga menziesii), sweet cherry (Prunus avium) and birch (Betula sp). The understory in this area was dominated by invasive English ivy (Hedera heli) which was partially removed by Metro maintenance, Where the ivy had been removed the understory ‘was scattered ivy and bare soil. Along the creek areas, Himalayan blackberry (Rubus armeniacus), common horsetail (/quisetum arvense) and impatiens (Impatiens noli-tangere) were also present Schott and Associates - Beologists and Wetland Specialist 21018 NE Hwy 99F, P.O. Box $89, Aurora, OR, 97002.- $03,678, 6007 - 503.678.6011 (fix) Page 2 ‘S&A Project #2321Onsite Resources The site is mapped within the Southwest Hills Resource Protection Plan Area. The western part of the site is located within Site #116: Capitol Hill/Burlingame. The majority of the site and all of the proposed impact area are located within Site #117: Stephens Creek/River View Cemetery. As identified by the City of Portland zoning map the majority of the property was mapped within the Environmental Conservation overlay (“c”) zone with a central portion along Stephens Creek mapped within the Environmental Protection (“p”) overlay zone. Resources listed in Site 116 are perennial creek, open space, forest, wildlife habitat, wetland, groundwater recharge, scenic, recreation and cultural. Resources listed in Site 117 are perennial creek, ‘groundwater, scenic, open space, wildlife habitat and corridor, forest, education and historic, Wildlife habitat was rated for each site using the Wildlife Habitat Assessment, Ratings for each site were provided in the Habitat Protection Plan (See Table 1 below). Schott and Associates rated the subject property as a whole, Ratings for water functions were relatively high due to the presence of two perennial streams and small wetland areas. Ratings for food and cover were low due to low species diversity and availability of food Table 1. Wildlife Habitat Ratings Site 116 Site 117 Subject Property Function | Rating Rating Rating Water Moderately [Medium | Moderately High |__| Migh _ Food Moderately | Moderately | Low High High Cover Medium Moderately | Low High Tnterspersion [Medium [Medium | Low Uniqueness_| Low Low ‘Low. Disturbance_| Medium Low | Low A wetland delineation and site assessment was conducted to identify and delineate any onsite water resources and to assess the functions of any and all onsite resources, The dominant resource in this site is a primarily deciduous forested area surrounding a perennial drainage known as Ruby Creek (a tributary to) and the main stem of Stephens Creek. The tributary is incised, especially at the upper end, and rapidly eroding with sewer pipe exposed in several locations or half buried and mounded over with soil along the bottom of the remainder of the tributary. ‘The main stem was wider and shallower with a width ranging from seven to ten feet. Gradient was low and substrate was a mix of cobble and silt, with a section of boulders. The southern side of the creek was steep while to the north were terraced benches with some delineated wetlands. Based on information gathered in the field, two wetlands totaling 0.15 acres were identified within the project area. Schott and Associates ~ Fcologists and Wetland Specialist 21018.NE Hwy 998, P.O, Box 589, Aurora, OR. 97002 - 503.678.6007 - 503.678.6011 (fax) Page 3 ‘SRA Project #2321Wetland # 1 was a 0.11 acre Palustrine Emergent Wetland (PEM) located along the northern boundary of Tax Lot 1300, west of SW Canby St and associated houses. The wetland was, approximately 15-20 feet northeast of the creek and 3-4 feet higher in elevation, The wetland was located in a slight swale at the toe of a slope. The northern end of the wetland was not within property limits, The wetland sloped south to merge with Stephens Creek. Vegetation was dominated by creeping buttercup (Ranunculus repens), northern bedstraw (Galium boreal) and common horsetail (Equisetum arvense). The adjacent upland was dominated by nettle-leaf (Agastache urticifolia) and blue wild rye (Elymus glaucus), ‘Wetland # 2 was a 0.04 acre PEM wetland located adjacent to a steep bank along the northern border of Tax Lot 1300, east of Wetland #1. Hydrology was present seeping down the steep hill forming the wetland in a small depression, Vegetation was predominantly creeping buttercup. In the adjacent upland vegetation was dominated by long-beak stork’s bill (Erodium botrys). In addition to the jurisdictional water features described above, a small depression was identified in the southwest portion of the site, This feature was described in the geotech report as an “area of seasonal ponding and overland stormwater flow.” This depression had been dug by one of the adjacent property owners and was not a natural feature. At the time of the wetland delineation, a ditch was observed, draining the ponding area and it did not hold water. Wetland criteria were not met and this feature was not identified as a natural resource to be protected. At the eastern edge of the property ‘was a small swale which the City and geotech identified as “drainages” or “gullies.” This area was visited during the wetland delineation and no onsite drainages were identified. A sample plot was located at the lowest point onsite just at the property boundary. No defined drainage channel was present onsite in this location. At the time of the site visit, the site was dominated by a mid-successional stage forest community dominated by deciduous big leaf maple. A climax community would be a mixed forest with Douglas firs being the dominant species, and big-leaf maple and western red cedars would be sub-dominants. A few Douglas fir and western red cedar trees (Thuja plicata) as well as some non-native trees were also present. This forest is representative of communities developing under repeated disturbance rather than being able to naturally mature to @ climax coniferous community characterized by Douglas fir, Western red cedar and big-leaf maple. ‘The understory in this area was dominated by invasive English ivy but included a few sword fern (Polystichum munitum). Invasive species removal has been conducted through portions of the site, reducing total biomass, but not effectively controlling it. Scattered hazelnut (Corylus cornuta) trees were present in the lower canopy as were areas of Himalayan and trailing blackberry. Where ivy had been removed the understory was mostly bare soil. Along the creek a few Oregon ash (Fraxinus latifolia) and red alder (Alnus rubra) were observed. Patches of common horsetail and impatiens were also present Contiguous wildlife habitat consisting of a forested swath along the creek extended west beyond the site to Interstate 5. To the east, across Taylors Ferry Road was River View Cemetery, which although managed, provides additional contiguous undeveloped habitat area, Resources and functional values identified onsite include perennial creek, open space, forest, wildlife habitat and corridor, wetland, ‘groundwater recharge and scenic, The site is currently under private ownership limiting opportunities Schott and Associates ~ Ecologists and Wetland Specialist 018 NE Hwy 991:, PO, Box 58 o Page 4 ‘SKA Project #2321for recreation and education but there is significant potential for these functions if the proposed open space area is given to the public. Section 33.430.405- Correction Options Violation 1 ‘As indicated in the Violation Notice dated May 13, 2015 the applicant is to obtain a zoning permit to replant cut and pruned shrub plantings in accordance with LU 06-107286, and add the tree topping to existing land use review under review. As part of this Environmental Review the applicant requests a zoning permit to replant additional trees and shrubs to mitigate for cut and pruned shrubs Violation 2: A subsequent violation was reported, consisting of ground disturbance with a track machine within the Resource area of the EC zone without required review. Addition of Environmental Review for this activity is added to this Review for proposed development. As per 33.430.405.D Option Three Environmental Review for the violation activity is provided herein using the approval criteria and procedures as outlined below. 1. Approval criteria. The approval criteria of Subsection 33.430.250.G must be met. See below 2. Review procedures b. Type Il. All other environmental reviews to correct environmental code violations are processed through a type II procedure. c. All environmemal reviews must provide the information required in Section 33.430.240, Supplemental Application Requirements Information identified in 33,430.240.B,1 and B.3 is provided in this report. The required map shall be included with this report showing impacts and mitigation area, Section 33.430.210-280 —ENVIRONMENTAL REVIEW 33.430.240.B 1 Impact Evaluation Development Plan The proposed development consists of 23 detached single-family houses with access off Hume Street from SW Taylors Ferry Rd or SW Ruby Terrace and a single new public street (Street A) with a cul- de-sac at the north end, The project will include development of the residential streets, including a revised layout for SW Hume Street connecting to SW Taylors Ferry to the south, Schott and Associates - Beologists and Welland Specialist 21018 NE Hwy 99F, P.O. Box 589, Aurora, OR_ 97002 - 503.678.6007 - 803.678.6011 (ins) Page 5 SALA Project #2321Almost the entire subject property is located within the Environmental Zone. Area of permanent impact in the environmental conservation zone is 199,217sf. Total temporary disturbance within the environmental conservation zone is 5,487sf. Temporary disturbance in the environmental protection zone is 2,548sf for the stormwater outfall and sewer line connection. The site is well forested and a total of 527 trees including 30 nuisance trees will be removed for lot development, right-of-way improvement and utilities, As per 3.430.250 Environmental Review is required when a proposal does not meet one of the development standards of Section 33.430.140-170 or subsections 150-190. Alll standards are met for this proposal except for those outlined below. 33.140.160 Standards for Land Divisions and Planned Developments D. The total amount of disturbance allowed within the resource area of the environmental conservation zone is either the amount listed in table 430-4 (15% of the site) or 1 acre, whichever is less, minus the amount of area outside the resource area; The subject property is zoned R10. Based on the table, maximum allowed disturbance area is exceeded by the proposed activity. This standard is not met and Environmental Review is required F. Tree removal is allowed as follows: 1. Native Trees. In residential zones, the combined total diameter of native trees may not exceed 225 inches per dwelling unit, counting only native trees that area at least 6 inches in diameter. In all other zones native tree removal is limited to the boundaries of the approved disturbance area. Native trees must be replaced as shown in Table 430-3; ince trees. Non-native non-nuisance trees may be removed, but must be ible 430-3; and 2. Non-native non-nuis replaced as shown in 3. Nuisance trees. Trees listed on the Nuisance Plants List may be removed, but must be replaced. Kach tree 6 or more inches in diameter must be replaced with one native tree. Proposed development includes removal of a total of 527 trees for lot, utility and right-of-way (ROW) improvements. Total number of trees to be removed within the 23 lots is 297. Total DBH of trees to be removed has been calculated for each lot separately as well as for the ROW and Tracts. Total DBHL of removed trees within each separate lot is less than 225” per lot except for in Lots 1, 2, 3, 4, 6, 8, 9, 13, 14, 15, 16 and 23. (See attached table). This development standard is not met and Environmental Review is required. J. Utility construction must meet the applicable standards of Section 33.430,150. Private utility lines ‘ona lot where the entire area of the lot is approved to be disturbed and where the private utility line provided conmecting service directly to the lot from a public system are exempt from this standard. Al utility lines, except for the stormwater outfall addressed in a separate standard, are on lots where the entire area shall be disturbed and the private utility line provides connecting service directly to the ott and Associates — Feologists and Welland Specialist 21018 NE Hwy 99F, P.O, Box $89, Aurora, OR. 97002 - 503.678, 6007 - 503.678.6011 (fa Page 6 ‘SRA Project #2331lot from a public system and are exempt from this standard, Trees removed within utility easements shall be included within the total removed within lots and/or right of way and mitigated accordingly. 33.430. 180 Standards for Stormwater Outfalls A. The temporary disturbance area for the stormwater outfall is no greater than 10 feet wide; The proposed temporary disturbance area for the outfall is approximately 30 feet wide. This standard is not met and environmental review is required B. Native trees 12 or more inches in diameter may not be removed. Each native tree, at least 6 inches but less than 12 inches in diameter that is removed must be replaced as shown in Table 430-3. A total of 18 native trees 12” or greater in diameter are proposed to be removed for the stormwater outfall. One additional tree greater than 6” dbh but less than 12” dbh is also proposed to be removed (Table 3). This standard is not met and Environmental Review is required. Mitigation for all 19 trees shall be provided as detailed in the overall mitigation planting plan (See Mitigation Plan) Table 2. Ouffall Trees Removed (within entire easement) Size [Scientific Name | Common Name | # removed 6-12" | Unk. Deciduous 1 13-20" | Acer macrophyllum | Big leaf maple [4 Alnus rubra Red alder 6 21-25" | Alnus rubra Red alder 3 ‘Acer macrophyltum | Big leaf maple 26-30" | Acer macrophyllum | Big leaf maple | Alnus rubra Red alder 1 F. Temporary disturbance areas must be planted with native species listed in the Portland Plant List according to the following densities: I. Three different native shrub species are required at a minimum I-gallon size or bare root, planted at a density of 3 plants per 10 square feet; and 2. The remaining area must be planted with native groundcover using a minimum of 4-inch pots at a density of 8 plants per 10 square feet. ‘Temporary disturbance area for the outfall and pipe location is proposed to be 8,035sf. This area shall be planted as outlined above. ‘This standard shall be met as outlined in the Mitigation Plan. H. Only one outfall pipe may be used on a site. The outfall pipe size may not exceed 4 inches in diameter; and One outfall is proposed for this project. Pipe sizing will be 12-18 inches as required to meet minimum. BES standard conveyance requirements and to adequately convey design storm events without inundating upstream dwellings (See Stormwater Management Plan), This development standard is not met and Environmental Review is required Schott and Associates ~ Reologists and Wetland Specialist 21018 NE Hwy 99F, P.O. Box S80, Aurora, OR. 97002 503,678 6007 - 503.678.6011 (fn Page 7 SRA Project #2321J. Ifan outfall riprap pad is used, it must be planted with live stakes of native plant stock one half inch in diameter. Stakes must be installed at a density of 2-3 stakes per square yard. ‘The outfall will require energy dissipation in the form of a riprap pad, Precise size shall be determined during final design stage but is assumed to be 10°x10” for preliminary purposes. The pad will be planted with live stakes of native Pacific willows at a density of 2-3 stakes per square yard (See mitigation planting plan). This standard is met. ection 33.430.250 Approval Criteri 33.430.250 A. Public safety facilities, rights-of-way, driveways, walkways, outfalls, utilities, land divisions, Property Line Adjustments, Planned Developments, and Planned Unit Developments. 1. General criteria for public safety facilities, rights-of-way, driveways, walkways, outfalls, utilities, Jand divisions, Property Line Adjusiments, Planned Developments, and Planned Unit Developments; a. Proposed development locations, designs, and construction methods have the least significant detrimental impact to identified resources and functional values of other practicable and significantly different alternatives including alternatives outside the resource area of the environmental zone; Almost the entire site is within an environmental zone and there is no practical alternative which will avoid all impacts. There is not adequate developable area for a viable alternative outside the resource area, In an attempt to minimize significant detrimental impact identified resources and functional values, the proposed development has been designed to avoid all permanent impacts to the Environmental Protection zone and has minimized impacts to the P zone to 2,548sf of temporary impact for the outfall and sewer connection. This area will be restored to good condition under the proposed mitigation plan, The lot layout is dictated by the property shape and constraints of slope and onsite water resources as described in the alternatives analysis below. The project has been significantly scaled back from the original plan to minimize detrimental impact to resources and functional values. ‘The proposed design has limited the development area to the flatter portion of the property on the south side of Ruby Creek and maintains a minimum 50-foot wide buffer between all proposed development and Ruby Creek. This provides the least detrimental impact on functions provided by the Regionally Significant Riparian Corridor. ‘The proposed buffer will continue to provide shade, intercept rain to reduce erosion from stormwater runoff, trap nutrients and contribute to instream biodiversity and channel structure, Additionally, the site provides and will continue to provide Regionally Significant Wildlife Habitat. The location of the development is contiguous with existing development to the south and completely avoids the larger contiguous and connected habitat to the north and adjacent to Stephens Creek. While proposed site development reduces the overall size of habitat, a significant open space tract identified as Tract A will be owned and maintained by the homeowners’ association and will include both onsite waterways which connect to offsite habitat. By reducing proposed development to a single area the proposed design minimizes the edge effect and Schott and Associates ~ Foologsts and Wetland Specialist 21018 NE Hwy 99H, P.O. Box 589, Aurora, OR, 97002 - 5 (678-601 (fax) Page 8 SBA Project #2321maintains the largest feasible interior habitat area while still developing the site, Connectivity will not be significantly affected as the open space tract will continue to connect with offsite habitat area to the east and no impacts to the connectivity of the onsite waterways will result from the proposed development Alternatives ‘An impact evaluation requires 2) Evaluation of alternative locations, design modifications, or alternative methods of development to determine which options reduce the significant detrimental impacts on the idemified resources and functional values of the site; and (3) Determination of the alternative that best meets the applicable approval criteria and identify significant detrimental impacts that are unavoidable. ‘The proposed layout of 23 lots and overall process of collaboration with city staff has significantly reduced the area of the originally-proposed development from 60 to 23 lots and limits proposed isturbance area entirely to the southern portion of the property. ‘The maximum density allowed for the site is $0 units, There is a framework of policy direction that encourages meeting density and utilizing land efficiently inside the Urban Growth Boundary. Sites with existing infrastructure and zoning should be developed close to density maximums but with attention to maintaining the existing character of the surrounding neighborhood. There is no minimum density requirement due to the E overlay zoning Surrounding residential land use, with the exception of the cemetery, is all single-family housing, Based on the various residential zones in the area, the applicant determined that single-family houses ‘would meet local market demand and be the most compatible fit in the neighborhood. The proposed plan is for 23 lots for detached houses as discussed with the city planning staff and in accordance with the existing character in the neighborhood, as well as complying with the bulk of the dimensional standards of the R10 zone, Design constraints included transportation requirements and environmental zoning through most of the site, All lots will be accessed by a public street system that provides connectivity per city standards. Only two access points are available to the site, and the available site development area dictates that only two rows of houses can be placed along each residential street. The P overlay zones will be avoided completely, with the exception of a temporary construction disturbance for the proposed outfall at the northeast end of Ruby Creek, and preserved in Tract A. Impacts within the C overlay areas will be minimized as much as possible. The mausoleum and cemetery located south and east of the site are located in open space zoning, further limiting the development options. These constraints dictate in large part the proposed design. Alternative 1 This option includes 37 lots with an average size of 6,498 sf. Twenty-three (23) lots are proposed on the south side of the Ruby Creek drainage way and the balance are proposed to the north of the drainage way. Access is to the lots is provided by a rather lengthy cul-de-sac extended from the southern connection to Taylors Ferry Road, The access road would cross over Ruby Creek by Schott and Associates ~ Ecologists and Wetland Specialist 21018 NE Hiwy 99; RO, Box. 589, Aurora, OR, 97002 - 503.678.6007 - $03.678-601 (fas) Page 9 ‘S&A Project #2321stalling an arched culvert or short bridge span section, The site impact is extensive with this option. This option includes the bridge section over Ruby Creek and its P zone designation. It also includes larger-sized single-family lots and a larger development and impact footprint atthe site. There would likely be resistance to the actual length of the cul-de-sac and access for emergency vehicles. This alternative results in significantly greater impact to the resource than the proposed and was rejected. Alternative 2 This option includes 23 lots with an average size of 6,796 s.f, The 23 lots take access directly from a public road that terminates in a cul-de-sac south of the Ruby Creek drainage way. This option avoids impact to the Ruby Creek P zone area with the exception of sewer/stormwater connection at the northeasterly end of Ruby Creek. However, this option still results in significantly greater resource impact due to the larger lot sizes resulting in permanent impact area and tree/native vegetation removal, Also, there is no open space zoned land to the east of the site, This alternative was rejected Alternative 3 This option includes 38 lots with an average size of 3,480 s.f. Ten (10) lots are accessed by an alley that forms a loop. Front entries to the 10 homes are oriented around a green commons. Twenty-eight (28) lots front on and take access from a conventional street with on street and on lot parking provided. No buffer is provided behind the adjacent four (4) lots that exist on Ruby Terrace Drive. The access to Taylors Ferry Road is laid out directly adjacent to an existing unimproved public right-of-way. This access road location requires excessive cut and grading to implement per city standards. This option was reviewed with city staff and received negative comments. Although it avoided EP area impacts along the Ruby Creek corridor, the opinion was that tree removal and grading impacts were too great. Impacts were not minimized enough to be acceptable to staff. Alternative 4 This option includes 23 lots with an average size of 5,331 s.f. All lots are at least 5000 s.f. The majority of the 23 lots all take access directly from one proposed public street that terminates in a cul- de-sac. Lots 1 and 2 and 12 through 14 take access from SW Hume Street. This option avoids impact to P zone areas and the Ruby Creek corridor. The only impact to the P zone is a sewer/stormwater outfall connection to Ruby Creek at the northeasterly end. The access point to Taylors Ferry Road is shifted downslope to the east in this option. It reduces cut/grading requirements and creates a safer intersection. Mitigation for onsite impacts for all of the above options consists of enhancement of upland forest and riparian habitat as well as re-routing of a section of failing sewer line within Ruby Creek, The mitigation plan outlines proposed activity, including removal of invasive cover and replacement with native trees, shrubs and groundcover throughout the surrounding basin. The existing forest consists of predominantly big leaf maple which came in after logging and represents an earlier, less mature stage of ecological succession. The understory is dominated by non-native species and bare ground. Proposed plantings will be primarily conifers and native understory with the intent to move the site towards a more mature coniferous community, providing greater ecological function including erosion control, interception of water, and habitat value. The re-routing of the existing sewer line is a Schott and Associates ~ Ecologists and Wetland Specialist 991, PO, Box $89. Aurora, OR. 970K ‘SEA Project #2321significant public improvement eliminating a potential failure of sewage directly into the creek and increases the overall value of mitigation for proposed impacts. ‘In spite of significant impact to the c zone the proposed design has been identified as the one that best meets all applicable approval criteria except as identified in this Analysis. Because of this, the application is provided for Environmental Review ‘Schott and Associates ~ Heologists and Wetland Specialist |018NE Hiwy 99E, P.O. Box 589, Aurora, OR. 97002 503,678 6007 Page 11 ‘S&A Project #2321ALTERNATIVE DESIGNS 1-4 ‘Schott and Associates — Foologists and Wetland Specialist, ‘21018.NE Hwy 998, P.O, Box 589, Aurora, OR. 97002 - $03,678,6007 - 503.678.6011 (fa) Page 12 ‘S&A Project #2321g10z/e0/z0 %L Ov 38 \OL'Z¥e Bary SOEs e'6s %6'9€ ST Uejq JUaWdojaneq EAE] | abpry wepeoeyy | SAneUlayy)oiteiowzy) Ni 00z 00) 0 %PLI JS ASB"LOP ‘Bay aoeds: %9ZE 48 L6h'P6} ‘Bary eouRdut | wee | %Se wet, BUS 10% > Ue} JuaWdojenag eAneUeyy abpry wepeoew 7% SAHEUIA}Y { sexy 16° Bases V }02IL 80eds Lado) oN | [ep one Xe Sit CRC pay i He tenSHGEBOIZO: 00z__ 00 0] a 719 ;panowai 8q 0) Sead] 1 ‘BIS 10% % uel ‘uowdojeneg AEWA abpry wepesey Lo € OAyeUarypeated oz oor 0 eS io | £2 $8107 Jo oquiny FL lue|q Juawudojanag eajewey|y| abpry wepeseyy y SAHeUSy Vy4. There will be no significant detrimental impact on resources and functional values in areas designated to be left undisturbed; Areas to be left undisturbed are contiguous and largely located along both drainage channels wi the p zone and in the entire northern portion of the site, well away from proposed disturbance. For the areas directly adjacent to proposed development, the disturbance area has been generously calculated with the intent that impact to the remaining trees will not result, Mitigation is proposed along Ruby Creek and its adjacent slopes which will include continued removal of invasive groundcover and planting a mix of native trees, shrubs and herbaceous species. This will provide greater erosion control, absorb precipitation, and significantly improve wildlife habitat including cover and food. A. tree protection plan has been provided by the arborist as part of this report (See Arborist Report) to ensure that there is no detrimental impact to existing native trees, Significant detrimental impact on resources and functional values in areas designated to be left undisturbed are not anticipated Regionally Significant Riparian Corridors: Vegetated riparian corridors provide important natural watershed functions. Tree canopy shades streams, helping to keep streams cool. Riparian vegetation helps to stabilize stream banks, capture sediment in stormwater runoff, support the water cycle and the cycling of mutrients, and provide a source of woody materials to the streams. The proposed design has limited the development area to the south side of Ruby Creek and maintains a minimum 50-foot -buffer between all proposed development and Ruby Creek. The resource to be left undisturbed including the proposed buffer will continue to provide shade, intercept rain to reduce erosion from stormwater runoff, trap nutrients and contribute to in-stream biodiversity and channel structure, Riparian vegetation will be maintained allowing the stream corridor to continue to function asa wildlife corridor Regionally Significant Wildlife Habitat: These resources provide important feeding, breeding and rearing habitat for native wildlife. The wildlife resources on this site provide and will continue to provide a relatively large habitat patch size, interior habitat and connectivity. The location of the proposed development is contiguous with existing development to the south and completely avoids the larger contiguous and connected habitat to the north and adjacent to Stephens Creek. While proposed site development reduces the overall size of habitat a significant open space tract will be maintained which will include both onsite waterways which connect to offsite habitat, By reducing proposed development to a single area the proposed design minimizes the edge effect and maintains the largest feasible interior habitat area while still developing the site. Connectivity will not be significantly affected as the open space tract will continue to connect with offsite habitat area to the east and no impacts to the connectivity of the onsite ‘waterways will result from the proposed development. The mitigation plan will restore temporary disturbance areas to a natural state by replacing with native trees, shrubs and herbaceous species. The existing forest designated to be left undisturbed contains a moderate to high canopy of native trees with an understory dominated by invasive species. All native trees in this area shall be retained, As called for in the mitigation plan, invasive species shall be removed and replaced with native understory species. Additionally, the addition of coniferous tree species will improve habitat and diversity, moving the site closer to a more mature successional stage Schott and Associates ~ Fcologists and Wetland Specialist 21018 NE Hwy 998, P.O. Box $89, ‘OR, 97002 = $03 67 Page 13 ‘S&A Project #2321 GOO - 503.678.6011 (fa)One construction entrance will be located at Taylors Ferry Road at the entrance of SW Hume St. A. stockpile area and staging area will be located in the southwest part of the site west of Street A. (Sheet P6.2) Sediment fencing shall be placed around the edges of all grading/disturbance areas adjoining, undisturbed resource area, Inlet protection will also be provided. Setbacks and transition areas shall bbe maintained to minimize impact from development. ¢. The mitigation plan demonstrates that all significant detrimental impacts on resources and functional values will be compensated for: ‘The proposed development plan shows 199,217sf of permanent disturbance area in the EC zone and no permanent impacts in the EP zone. Temporary impacts proposed are 5,487sf in the EC zone and 2,548sf in the EP zone. The plan also proposes a total of 527 trees to be removed from the resource area, including 30 which are nuisance species. Mitigation shall take place onsite to best replace lost functions and values. The mitigation plan is designed to mitigate for the loss of resource area and functions from the proposed development. The plan calls for upland and riparian forest enhancement throughout the remaining property, adjacent to both Stephens Creek and Ruby Creek drainage to improve diversity, habitat and erosion potential along the slopes. Invasive ivy and other non-native species which dominate the understory will be removed. Cleared areas will be enhanced by the planting of native trees and shrubs as shown on the proposed planting plan. Temporary disturbance areas shall planted as required and included within the Mitigation Plan, All plants will be located on the Portland Plant List. See Mitigation Plan. Detrimental effects from the proposed development are due to the conversion of undeveloped area to impervious non-vegetated development. Identified development impacts and mitigation measures areas are described below and in the Mitigation Plan. Water Quality Impacts ‘The applicant proposes to convert approximately 4.4 acres of forest to impervious development. Reduction of vegetation combined with the increase in impervious surface will increase stormwater runoff with the potential to increase erosion and exacerbate existing channel erosion within Ruby Creek. A stormwater management plan has been drafted to account for the additional stormwater runoff which will include water quality treatment. A minimum 50-foot forested buffer will be ret and enhanced along Ruby Creek which will continue to reduce overland runoff and trap nutrients and sediment. d Existing vegetation both in the upper flats where development is proposed and throughout the project area, consists of a moderate canopy of predominantly big leaf maple and an understory dominated by English ivy which is growing into the trees. English ivy has been removed in some areas, but these areas have been left mostly bare and/or are re-growing with ivy. Proposed mitigation for loss of this relatively low value community is to remove invasive English ivy, holly and Himalayan blackberry and replant densely with a mix of native shrubs and groundcover including sword fern and Oregon grape. Trees will also be planted to provide denser and more diverse canopy and structure as well as increasing soil stability and mitigating for any lost sediment and nutrient retention functions. These mitigation activities will ripple downstream by reducing erosion problems within Stephens Creek and Schott and Associates - Ecologists and Wetland Specialist 21018 NE Hwy 99E, P.O. Box 589, Aurora, OR_ 97002 ~ 503.678.6007 -$03.678.6011 (fax) Page 14 SQA Project #2321Ruby Creek and overall contributing to the City’s goal of restoration within this stream system Mitigation is provided for impact to this function, Hydrology Impacts As discussed above, increased impervious surface and resulting increase in stormwater runoff has the potential to increase flows and exacerbate existing problems in Ruby Creek and Stephens Creek. Flow modeling has been conducted for the stormwater management plan and all requirements are met to minimize the potential for such negative impacts. This information is addressed in the Stormwater Management Plan, Habitat and Wildlife Impacts ‘The applicant proposes to remove 497 non-nuisance trees within a 4.4 acre area, The proposed impact area is within a larger forested area (14.17 acres onsite) and approximately twice the impacted area (8.8 acres). The majority of the site (9+ acres) is proposed to be maintained in a protected open space tract, Habitat will be lost due to the area lost, however approximately 69% of the onsite forested area and all of the water resource will be retained. ‘The onsite forest is contiguous with Riverview Cemetery to the east and the larger habitat corridor continues south and east on the other side of ‘Taylors Ferry consisting of Riverview Cemetery and Riverview Natural Area. To the northwest contiguous habitat is cut off by 1-5. The overall wildlife corridor and connectivity, though decreased in size will not be negatively affected by the proposed development and due to the creation of the tract may even firther protect the identified Westside Wildlife Corridor. The proposed mitigation will focus on enhancing the remaining upland forest to a high quality community providing a contiguous habitat along both Stephens Creek and Ruby Creek. Mitigation shall also include the riparian areas adjacent to the creeks ensure high quality riparian habitat providing food, cover and nesting options for a variety of birds, mammals and other species. Proposed mitigation will include replacing trees lost with native trees and shrubs appropriate for high quality habitat in this region at a ratio appropriate for this site. Due to the existing high canopy and low understory structure the applicant proposes to focus on removal of invasive cover and replacement with a variety of native shrub species to increase food and cover options for wildlife. Additionally, where openings allow, the applicant proposes planting conifers to increase species diversity and move the existing forest towards a more mature successional stage. The northern flying squirrel, reportedly observed on site, is described as utilizing deciduous forest but preferring coniferous or mixed woods. Presence of this species may be encouraged by proposed mitigation activity (www iucnredlist.org/details/...2000 IUCN Red List of Threatened Species). Nesting Birds As requested by BES the applicant shall make an effort to avoid tree removal during the primary nesting season of April 15-July 31, If tree removal is necessary during this time the applicant will survey for trees slated for removal during early nesting season (April 1-April 25) and avoid removing any trees with an active nest until the young have fledged. cologists and Welland Specialist P.O Box $89, Aurora, OR, 97002 - $03 678.6007 - 503.678.6011 (fa S&A Project #2321Stephens Creek All development activity adjacent to Stephens Creek has been removed from this application, Violation activity defined as cutting and topping of trees and shrubs within the environmental zone and planted as mitigation for LU 06-107286 EN took place in the riparian zone along Stephens Creek The cutting was limited to pruning and topping for survey visibility and will not result in long term negative impacts to the wildlife habitat or creek function. Trees are regrowing and the area of impact is not clearly discernable. Mitigation for these impacts will be included in the riparian enhancement along Ruby Creek and its corridor. Proposed mitigation is anticipated to have positive impact on Stephens Creek, The entire adjacent forested area will be enhanced through removal of invasive species and planting with a mix of native species. This will improve water quality, erosion control, and habitat functions. Ruby Creek As previously discussed, Ruby Creek is eroding and portions of the in-stream sewer pipe are exposed and threatened by future high flows. This degraded condition is ongoing and is not a result of proposed development, Increased stormwater runoff to the creek has the potential to further exacerbate channel erosion, Proposed mitigation shall include re-routing the most degraded section of pipe by running it through the development and tying into the existing line below the exposed areas. This eliminates the likely failure of the sewer line within Ruby Creek which could cause negative polluting effects downstream into Stephens Creek and even as far as the Willamette. Adjacent to the creek, and through the valley, mitigation activities shall consist of removal of invasive species and planting with a diverse assemblage of native shrubs to increase habitat structure and diversity along the stream corridor. Mitigation shall be carried out as follows: * Removal of non-native plants. Planting of native trees and shrubs to replace lost vegetation and enhance existing forest. © Riparian zone restoration planting © Re-routing of the sewer line Construction details including work area isolation and sanitary sewer protection information is described in greater detail in the Stormwater Management Plan and/or Erosion Control Plan. Trees and shrubs will be located onsite under the direct supervision of the project biologist due to the presence of existing trees onsite. Tree removal tables have been calculated by lot to indicate total DBH lost per lot (See attached tables). Total number of trees to be removed onsite is 527 including 30 nuisance species. The existing forest canopy is moderate to high but shrub cover is low. Proposed planting is focused on replacing bare ground and invasive understory with a diverse planting of native shrubs. Conifers shall be planted where space is available for planting additional trees. iming Mitigation planting shall occur in winter following the beginning of the construction and be carried out in accordance with Section 33.248.090 Mitigation and Restoration Plantings. Schott and Associates ~ Ecologists and Wetland Specialist 2IDISNE Hwy 99E, P.O, Box 589, Aurora, OR. 97002 - $03,678,007 «503.678.6011 (fin Page 16‘As stated in this section, monitoring of landscape areas is the ongoing responsibility of the property owner. Plants that die must be replaced in kind. Written proof that all specifications of this section have been met must be provided one year after the planting is completed. The property owner must provide this documentation to BDS. Monitoring will be carried out as described below. Monitoring and Contingencies ‘As required by this section, the property owner will be responsible for ensuring that the mitigation area is monitored and maintained, Plantings will be inspected after installation and again at one year after planting (the first growing season) to check for survivorship and overall health. Any dead or dying plants will be replaced in kind unless it is determined that the site is establishing and plants replaced will not survive and are not needed. The site will be monitored again after the second growing season to ensure that the plants have established and will not require additional monitoring and maintenance, The city requires the applicant to submit Monitoring/Maintenance reports including the following: © Person doing the monitoring and submitting the reports. © Description of when the site was seeded and what seed mix was used. + Number and type of trees installed and if any died. Due to the high canopy cover onsite we are proposing 70% survivorship criteria © List of replacement plants installed (if any). Photographs of the mitigation area and a site plan showing location and direction of the photos. ‘© Description of the method and frequeney for watering of trees, shrubs and groundeovers for the first two summers after planting, ‘¢ Estimate of percent cover of invasive species (English ivy, Himalayan blackberry, reed canary ‘grass, teasel, clematis) within 10 feet of all plantings. Invasive cover must be no greater than 20%, d. Mitigation will occur within the same watershed as the proposed use or development and within the Portland city limits except when the purpose of the mitigation could be better provided elsewhere; and Mitigation shall occur onsite €. The applicant owns the mitigation site; possesses a legal instrument that is approved by the City (such as an easement or deed restriction) sufficient 10 carry out and ensure the success of the mitigation program; or can demonstrate legal authority 10 acquire property through eminent domain. The applicant is also the property owner. 33.430.250A.3.Rights-of-way, driveways, walkways, outfalls, and utilities; a. The location, design, and construction method of any outfall or utility proposed within the resource area of an environmental protection zone has the least significant detrimental impact to the identified resources and functional values of other practicable alternatives including alternatives outside the resource area of the environmental protection zone; ‘One stormwater outfall to the creek is proposed to extend into the environmental protection zone. The City of Portland requires that a project team first review options for infiltrating stormwater runoff from newly created impervious areas. The geotechnical engineer on this site has recommended that the ‘Schott and Associates — Feologists and Welland Specialist 21018 NE Hwy 9E, P.O, Box 589, Aurora, OR, 97002 - 503.678, 6007 - 503.678.6011 (fax) Page 17 ‘S&A Project #2321applicant does not infiltrate stormwater onto the site, but that instead stormwater is piped to an existing surface conveyance system. The site has steep slopes with significant existing near surface groundwater with landslide hazard potential, Based on this recommendation, all of the Low Impact Development facilities have been designed to be flow-through, conveying treated stormwater into a piped conveyance network rather than infiltrate on-site, The nearest conveyance networks on the site are Stephens and Ruby Creeks. Discharge points have been limited to a single outlet into Ruby Creek which coincides with the sewer connection points to the existing sanitary sewer mains that run along the creek avoiding the need for any additional impacts for sewer connection. This alternative is believed to be the one with the least detrimental impact. b. There will be no significant detrimental impact on water bodies for the migration, rearing, feeding, or spawning of fish; and No significant detrimental impacts to water bodies are proposed and no detrimental impacts on fish habitat are anticipated. The proposed sewer outlet will connect to an existing line located within Ruby Creek. Due to the presence of the existing sewer the connection will require minimal impacts. A temporary trench will be excavated and then backfilled to original grade for connection of the sewer line. This work is regulated by the Oregon Department of State Lands and Army Corps of Engineers, Any in-water work will be conducted during the dry season. The drainage shall be dammed uphill of the proposed work area and pumped downstream of the work zone. A stee! sheet or similar should be used to span the creek bend for use of construction equipment and material transport. CDF backfill should be use five feet on the proposed sewer trench, ¢. Water bodies are crossed only when there are no practicable alternatives with fewer significant detrimental impacts. ‘No water bodies are proposed to be crossed. 4. Land divisions, Property Line Adjustments, Planned Developments, and Planned Unit Developments: «a. Proposed uses and development must be outside the resource area of the Environmental Protection zone except as provided under Paragraph A.3 above. Other resource areas of Environmental Protection zones must be in environmental resource tracts; See A.3. above. All avoided areas of the Environmental Protection zone shall be located within a protected environmental resource tract (Tract A) b. There are no practicable arrangements for the proposed lots, tracts, roads, or parcels within the same site, that would allow for the provision of significantly more of the building sites, vehicular ‘access, utility service areas, and other development on lands outside resource areas of a conservation zone; and ‘The entire site is located within the conservation zone and no practical arrangement could develop the site on areas outside the conservation zone, As described in the alternatives discussion, the site layout, transportation constraints and environmental zoning of the entire site limits the practicable arrangements for proposed roads and lots within the site, ‘The development is located in the flattest area of the site with functional access point. Moving the northern-most lots (Lots 10, 11 and 23) Schott and Associates — Eeologists and Welland Specialist 21018 NE Hwy 99F, P.O. Box $89, Aurora, OR. 97002 - 503.678.6007 - 503.678.6011 (fx Page 18 ‘S&A Project #2321‘would move them onto a steeper slope area and closer to Ruby Creek and the EP zone, The connection to the sewer line is also fixed and would result in the need for a longer pipe and greater temporary impacts, This location would require more grading due to the slope and would actually result in greater impacts. All the proposed alternatives have similar layouts due to these constraints and the proposed option maximizes lot number while still maintaining the neighborhood aestheti minimizing overall development within conservation zone and maximizing open space within the site. ‘Approximately 69% of the site will be retained in an open space tract to be owned and maintained by Macadam Ridge HOA. ¢. Development, including building sites, vehicular access and utilities, within the resource area of a conservation zone must have the least amount of detrimental impact on identified resources and functional values as is practicable. Significantly different but practicable development alternatives, including alternative housing types or a reduction in the number of proposed or required units or lots, may be required if the alternative will have less impact on the identified resources and functional values than the proposed development. Development avoids impacts to onsite water resources and limits development to the flatter portions of the site with the ability to directly access residential streets. The development design process has gone through several rounds resulting in the proposed number and type of housing types. This design significantly minimizes impacts from previous designs by almost 50% and has altered housing design and layout in response to comments from the neighborhood and City. Four alternatives with a reduced footprint were considered with the proposed one being the least impactful, limiting all development to the area south of Ruby Creek. The proposed design intends to provide high-end affordable homes while maintaining the neighborhood aesthetic and preserving significant portions of the site in an open space tract. Detrimental impact on onsite resources has been minimized to the greatest extent possible while still developing the proposed project. No impacts are proposed in onsite waterways or directly adjacent buffers with the exception of the stormwater outfall which will outlet into the creek. The area disturbed for installation of the pipe and outfall will be restored in place. The remaining resource area will be placed in a tract and will provide significantly greater functions after mitigation and protection than currently provided 33,430,250 E. Other Development in the Environmental Conservation zone or within the Transition Zone only. 1. Proposed development minimizes the loss of resources and functional values, consistent with allowing those uses generally permitted or allowed in the base zone without a land use review. The violation activities took place in a low functioning forest habitat which was assessed to have low functions and values, Violation 1: Vegetation removed consisted of pruning/topping of vegetation planted in accordance with mitigation for a previous environmental review. The precise extents of this activity are not clear and the majority of the trees and shrubs have already grown back to their original size. ‘The activity was identified within both the C zone and the P zone as outlined below. cologists and Welland Specialist 21018 NE Hwy 99F, P.O, Box S89, Aurora, OR, 97002 » 503.678 6007 $03,678-6011 (Fax) Page 19 S&A Project #2321Violation 2: Ground disturbance with a track machine, resulting in minimal vegetation disturbance, primarily to invasive English ivy groundcover. Total area of disturbance was calculated to be 12,727s¢ and is already mostly restored to original condition, For both of these actions, areas within an existing habitat were disturbed resulting in some minor loss of resources and functions, For the most part, impacts were temporary with vegetation having grown back to nearly previous condition within one year, However, activities were considered a violation outside those uses allowed in a base zone without a land use review so this criterion cannot be met. 2. Proposed development locations, designs and construction methods have the least significant detrimental impact to identified resources and functional values than other practicable and significantly different alternatives, Violation 1; The violation location was determined by the city to be within a previously planted riparian mitigation area although it did not appear to have been planted material. While detrimental impacts from the activity are minor, it was not a permitted activity and cannot be said to have the least significant detrimental impact than other practicable alternatives. This criterion is not met. Violation 2: The violation area consisted of tracked roadways to and the locations of exploratory borings and other work conducted by the Geotech within the proposed development area for Macadam Ridge Subdivision, Based on the site assessment conducted by Schott and Associates and identified by the City, resources within the project area include Regionally Significant Riparian Corridors and Regionally Significant Wildlife habitat. Loss of cover was limited to removal of invasive English ivy groundcover. ‘Thus loss of functions including shade, water quality functions and organic inputs within the Riparian Corridor were not identified as impacts from the violation activity. Wildlife habitat was not significantly affected by the activity. Evaluation of wildlife habitat resources using the Wildlife Habitat Assessment Form was conducted for the project area and found to be Low for all criteria except for Water prior to the violation and were not significantly impacted by the activity. The violation activity was not a permitted activity and as such a practical alternative would have been not to conduct the activity or to conduct it with hand held equipment only and restored to pre-existing conditions as allowed by Item 6 in 33.430.080 Items Exempt from These Regulations. This criterion is not met, 3. There will be no significant detrimental impact on resources and functional values in areas designated to be left undisturbed. Impacts are limited to the area of identified violations. No significant detrimental impacts on resources and functional values outside the area of impact have been identified or are anticipated from either violation activity. 4. The mitigation plan demonstrates that all significant detrimental impacts on resources and functional values will be compensated for. See Mitigation Plan, Schott and Associates - Ecologist and Wetland Specialist 21018 NE Hwy 99E., P.O. Box $89, Aurora, OR. 97002 - 503.678.6007 - 50367846011 (fax) Page 20 ‘S&A Project #23215. Mitigation will occur within the same watershed as the proposed use or development and within the Portland city limits except when the purpose of the mitigation could be better provided elsewhere. Mitigation will take place on site in conjunction with mitigation for the proposed development. e. The applicant owns the mitigation site; possesses a legal instrument thet is approved by the City (such as an easement or deed restriction) sufficient to carry out and ensure the success of the mitigation program; or can demonstrate legal authority to acquire property through eminent domain, ‘Yes. 33.430.250 F. Other Development in the Environmental Protection Zone. 1. All sites within the Portland city limits, in which the proposed use or development is possible, are also in the resource areas of Environmental Protection zones; Activity was a violation. This criterion cannot be met. 2. Of these sites, development on the proposed site would have the least significant detrimental environmental impact; Activity was a violation. This criterion cannot be met. 3. There is public need for the proposed use or development; Activity was a violation. This criterion cannot be met 4. The public benefits of the proposed use or development outweigh all significant detrimental impacts; Activity was a violation. This criterion cannot be met. 5. There will be no significant detrimental impact on resources and functional values in areas to be efi undisturbed; Activity consisted of minor topping of native vegetation which had been planted as mitigation for a previous project. No trees or shrubs were removed or killed and it will re-grow within 1 to 2 seasons. Impacts were limited to said topping and no significant detrimental impact on any other resource or functions occurred 6. The mitigation plan demonstrates that all significant detrimental impacts on resources and functional values will be compensated for; See Mitigation Plan. 7. Mitigation will occur within the same watershed as the proposed use or development and within the Portland city limits except when the purpose of the mitigation could be better provided elsewhere; and Mitigation will take place onsite 8. The applicant owns the mitigation site; possesses a legal instrument that is approved by the City sufficient to carry out and ensure the success of the mitigation program; or can demonstrate legal authority to acquire the property through eminent domain. Associates ~ Ecologists and Welland Specialist P.O. Box 589, Aurora, OR, 97002 » $03,678,6007 - $03,678-6011 (f ‘S&A Project #2321Yes Section 33.430.250 G. Corrections to Violations. For corrections to violations of this Chapter the application must meet all applicable approval criteria stated in subsections A through F above, and paragraphs 1, 2.b and 2.c, below. If these criteria cannot be met, then the applicant's remediation plan must demonstrate that all of the following are ‘met. See documentation of 33.430.250.E and F above. Criteria were not met. 1. The remediation is done in the same areas as the violation; and Mitigation is proposed as outlined in the mitigation plan. It shall take place onsite within the same forest resource, Topped trees were not removed and will re-grow in the same area as the violation Additional trees and shrubs shall be replanted throughout the entire Ruby Creek corridor, improving cover, habitat, diversity and diversity as well as reducing erosion and sedimentation into the creek. Ground disturbance consisting primarily of ivy removal occurred within the road ROW and proposed development site. It is not feasible to remediate the exact area of the ground disturbance violation which is to be developed in the near future. Mitigation shall occur with the same forest resource and result in higher functioning resource than what was impacted. Invasive species will be replaced with native species with greater diversity and cover than what was removed. 2, The remediation plan demonstrates that after its implementation there will be: a. No permanent loss of any type of resource or functional value; As indicated in this report, existing functions on the site are low. Proposed mitigation shall consist of removal of invasive species and planting of a variety of native trees, shrubs and groundcover species to bring an adjacent portion of the same forest to a higher functioning condition, providing significantly greater Food and Cover through increased species and structural diversity. Minimal loss of actual resource occurred from the unauthorized activity although there was some loss of cover and || movement. Any impacts to the low functioning forest community will be mitigated through enhancement of comparable portion of the same low functioning habitat, Proposed mitigation consists of a widescale enhancement of the entire Ruby Creek corridor providing a higher quality forested habitat directly adjacent to the onsite waterway. The entire mitigation area shall be placed in attract with improved functional value. Loss of value from the violation impact is not anticipated to result in overall loss of any type of resource or functional value. 5. A significant improvement of at least one functional value; and Significant improvement of food, cover and diversity functions are anticipated from the proposed mitigation activity, Species to be planted will consist of a diverse palette of native species increasing structural diversity, cover and nesting options, escape options, variety and quality of food. Nearly all species proposed are indicated by the Portland Plant List as providing food for a variety of birds as Schott and Associates ~ Ecologist and Wetland Specialist 21018 NE Hwy 998, P.O. Box $89, Aurora, OR, 97002 - 503,678,607 » 503.678.6011 (fin) Page 22 S&A Project #2321well as both small and large mammals. Species to be planted include Douglas fir, Indian plum, service berry, snowberry and Oregon grape which provide seeds, fruit, buds, needles, bark, foliage and twigs. ¢. There will be minimal loss of resources and functional values during remediation until the full remediation program is established. Impact to the resource area consisted of topping trees and shrubs in a small area adjacent to the creek. Significant loss of functions did not occur as a result of the violation, Additional impact from Violation 2 was to an area of 12,727sf which was limited to loss of English ivy cover and some minor earth movement. Loss of resources and functional values during remediation will be minimal as well ‘The mitigation activity is proposed within the same forest habitat. Existing non-native and nuisance vegetation shall be removed and replaced with native species to improve habitat and diversity. Planting will take place as soon after clearing as possible to minimize any loss of functional values. As per 33.640.200A Stream, Spring, and Seep Standards for Land Divisions and Planned Developments A Preservation in a tract. Streams, springs, and seeps must be preserved in a tract as follows: 1. The edges of the tract must be at least 15 feet from the edges of the stream, spring, or seep. The edges of a seep or spring are determined through a wetland delineation, performed by an environmental scientist, and approved by BDS. If one or more wetland characteristics are absent from the resource, the delineation will be based on the wetland characteristics present. The edges of a stream are defined as the top-of-bank. Where the edge of the stream, spring, or seep is less than 15 feet from the edge of the site, the tract boundary will be located along the edge of the site; ‘As described above the subject property was delineated by Schott and Associates. Wetland and water resources were mapped and will be contained in a 10.11 acre tract (Tract A) measuring well more than 15 feet from the edge of the delineated resource boundary, The City identified an unidentified headwater tributary to Stephens Creek on the eastern boundary of the site. While the wetland delineation did not identify any jurisidictional waters in this location, this area is included within the open space tract and will be more than 15° from either side of the centerline of the drainages. B. Development allowed in the tract or easement. The following development, improvements, and activities are allowed in the tract or easement: 1. Disturbance associated with discharging stormwater to the stream channel, if BES has determined that the site’s storm water carmot discharge to a storm sewer and BDS has determined that on-site infiltration is not an optio As described above, one stormwater outfall to the creek is proposed to extend into the environmental protection zone which will be placed in a tract. ‘The applicant’s engineers have met with BES to discuss options. There are no site storm sewers available for discharge, ‘The geotechnical engineer on this site has recommended that stormwater not infiltrate onsite, but that instead itis piped to an existing surface conveyance system, The site has steep slopes with significant existing near surface groundwater with landslide hazard potential, The geotech recommended installing horizontal Schott and Associates ~ Ecologiss and Wetland Specialist 21018. NE Huy 99E. P.O. Box S89, Aurora, OR, 97002 - $03 678, 6007 - 503.678.6011 (fa) Page 23 S&A Project #2321subsurface drains to mitigate this potential hazard. ‘The agreed upon approach discussed with BES is to provide flow-through planters and discharge to the existing streams. Typically, BDS would rely on BES to advise on stormwater issues including facility types, treatment, detention, and infiltration. With that in mind, all of the Low Impact Development facilities have been designed to be flow-through, ultimately conveying treated stormwater into a piped conveyance network rather than infiltrate on-site. ‘The nearest conveyance networks on the site are Stephens and Ruby Creeks. Discharge points to the streams have been limited to one to Ruby Creek coinciding with a sewer connection point to the existing sanitary sewer main that runs along this creek avoiding the need for any additional impacts for sewer connection, This alternative is believed to be the least detrimental impact. Schott and Associates ~ Hoologists and Welland Specialist 21018 NE Hwy 99, P.O, Box 589, Aurora, OR, 97002 - $03,678,607 - $08.678-6011 (fs Page 24 S&A Project #2321